Tax Senior Manager, Transfer Pricing

BDO USA; San Jose (CA); On-site; USD 100,000 - 263,000; Full time

Job summary

BDO USA is seeking a Tax Senior Manager, Transfer Pricing to advise clients on TP implications, develop strategies, and ensure compliance with IRS and OECD guidance, while driving business development. You will lead engagements, supervise staff, perform analyses, and present to prospective clients.

Eight+ years of TP experience and a Bachelor's in Accounting or related field required; Advanced degree preferred.

Qualifications

• Bachelor's degree required in accounting, finance, economics, or related field.
• Eight or more years of transfer pricing experience required.
• Experience supervising professionals on projects or engagements; ability to manage teams.

Responsibilities

• Advise clients on transfer pricing implications and compliance.
• Lead project scoping, budgeting, and client presentations.
• Supervise engagement teams to ensure high-quality deliverables.
• Develop transfer pricing methods and prepare planning/documentation reports.
• Review tax provisions and support FIN 48 considerations.

Skills

Verbal & written communication

Analytical & research

Leadership & supervision

Business development / networking

Education

Bachelor's degree in Accounting/Finance/Economics or related field

Advanced degree preferred

Tools

MS Office

Excel

PowerPoint

Word

Tax research databases

Job description

JOB DESCRIPTION

The Tax Senior Manager, Transfer Pricing is responsible for advising clients of the transfer pricing implications relating to their business objectives, recommending alternate courses of action, as well as identifying different methods of complying with transfer pricing regulations. In this role, the Tax Senior Manager, Transfer Pricing will be charged with marketing, networking and business development within their area of experience and specialization and recognizing potential changes in tax policy and applying new policies to tax compliance.

Job Summary

The Tax Senior Manager, Transfer Pricing is responsible for advising clients of the transfer pricing implications relating to their business objectives, recommending alternate courses of action, as well as identifying different methods of complying with transfer pricing regulations. In this role, the Tax Senior Manager, Transfer Pricing will be charged with marketing, networking and business development within their area of experience and specialization and recognizing potential changes in tax policy and applying new policies to tax compliance.

Job Duties

• Research
  • Completes financial analysis related to intercompany transactions to include an evaluation of industry data and financial data provided by the client to assist in the documentation of appropriate intercompany pricing policies
  • Identifies when research is appropriate and frames issues to be researched
• Tax Compliance
  • Participates in determining the scope of transfer pricing projects, establishing project budgets and timelines and drafting and presentation of presentations to prospective clients
  • Administers the completion of the economic analysis and composes the final report
  • Ensures clients are compliant with transfer pricing requirements and proposes a year-end transfer pricing review, if applicable
  • Assists in determining appropriate transfer pricing methods under IRS regulations and analogous rules under the OECD Transfer Pricing Guidelines
  • Ensure tax engagement letters are adopted prior to engagement work commencing
  • Conducts detailed review of facts relating to transfer pricing and data and identifies basic, complex and advanced issues through the engagement
  • Manages engagement to achieve engagement metrics
  • Completes the project planning process and scheduling
• Tax Controversy
  • Represents clients before any tax authority on contested issues, as appropriate, and with assistance and guidance from senior Transfer Pricing professionals
• Transfer Pricing Consulting and Documentation Services
  • Develops, recommends, and implements appropriate transfer pricing methods (by type of transaction) to specific situations
  • Prepares planning/documentation reports
  • Applies transfer pricing regulations relevant to particular types of transactions when analyzing client business and financial data and identifies any issues
  • Analyzes the applicability and implications of new regulations and reports those findings to Tax Senior Director and/or Tax Principal
  • Recognizes need to utilize other expert resources, internal and external, to assist with engagements, as needed
  • Identifies opportunities for additional consulting specialties and federal tax cross selling opportunities and presents possibilities to appropriate members of senior management
  • Analyzes client situation and tax goals and provides transfer pricing advice to maximize the benefits the client
• Tax Provision and FIN 48
  • Employs general principles in tax accounting and relevance of transfer pricing in tax provisions
  • Applies transfer pricing in the context of tax provisions and FIN 48
  • Reviews tax provisions related to transfer pricing
  • Partners with Assurance professionals to plan tax accrual reviews related to transfer pricing
• Practice, Staff and Business Development
  • Identifies opportunities and prepares and delivers presentations to pitch service capabilities to clients and potential clients
  • Prepares proposals, statement of work and engagement letters
  • Researches a variety of tax topics related to transfer pricing
  • Works on teams that summarize and report on recent transfer pricing developments
  • Drafts tax alerts that are used to communicate recent developments to an external audience
  • Creates slides for use in presentations to internal and external audiences
  • Prepares training materials and presents on topics of interest to internal audiences
  • Works on special projects to develop the practice, create efficiencies or improve process
• Tax Related Software
  • Uses tax research databases and other tax-related software in the completion of assigned tasks; knowledge of statistical packages is preferred
• Other duties as required

Supervisory Responsibilities

• Supervises the day-to-day workload of Transfer Pricing Managers, Senior Associates and Associates on assigned engagements and reviews work product
• Ensures Transfer Pricing Managers, Senior Associates, Associates and Interns are trained on all relevant tax software
• Evaluates the performance of Transfer Pricing Managers, Senior Associates and Associates and assists in the development of goals and objectives to enhance professional development
• Delivers periodic performance feedback and completes performance evaluations for Transfer Pricing Senior Associates, Associates and Interns
• Acts as Career Advisor to Transfer Pricing Managers, Senior Associates and Associates, as appropriate

Education

• Bachelor’s degree in Accounting, Finance, Economics, or other relevant field of study, required
• Advanced degree, preferred

Experience

• Eight (8) or more years of prior experience required
• Experience working within a transfer pricing practice, required
• Prior experience supervising professionals on a project or engagement basis, requiredExperience with review of tax provisions from a transfer pricing perspective, preferred
• Prior experience applying knowledge of the interplay between transfer pricing and other areas of tax, preferred

License/Certifications

• N/A

Software

• Proficient in the use of Microsoft Office Suite, specifically Excel, PowerPoint and Word
• Prior exposure to tax research databases and/or other tax-related software beneficial; knowledge of statistical analysis software, preferred

Language

• N/A

Other Knowledge, Skills & Abilities

• Excellent verbal and written communication skills
• Superior analytical and research skills
• Solid organizational skills especially ability to meet project deadlines with a focus on details
• Ability to successfully multi-task while working independently or within a group environment
• Proven ability to work in a deadline-driven environment and handle multiple projects simultaneously
• Capable of effective managing a team of tax professionals and delegating work assignments as needed
• Capacity to build and maintain strong relationships with internal and client personnel
• Ability to encourage team environment on engagements and contribute to the professional development of assigned personnel
• Executive presence and ability to act as primary contact on assigned engagements
• Ability to successfully interact with professionals at all levels
• Ability to research taxation topics and communicate or compose written analysis effectively
• Ability to network and develop business within Transfer Pricing
• Ability to successfully interact with professionals at all levels within and outside the Transfer Pricing practice
• Excellent research skills and project management

Individual salaries that are offered to a candidate are determined after consideration of numerous factors including but not limited to the candidate’s qualifications, experience, skills, and geography.

National Range: $99,750 - $262,500

Maryland Range: $99,750 - $262,500

NYC/Long Island/Westchester Range: $99,750 - $262,500

Washington DC Range: $99,750 - $262,500

About Us

At BDO, how we show up matters. We build strong relationships by supporting one another, our clients, and our communities with care, curiosity, and a commitment to helping one another grow and succeed. Here, you’ll find meaningful work, leaders invested in your success, and opportunities to build a career around what matters most to you.

Our purpose is to be the people our clients count on to grow with confidence and achieve what matters most. Our values guide how we bring that purpose to life each day. Together, they shape how we work with one another, serve our clients, and create meaningful impact.

BDO provides assurance, tax, and advisory services to clients across the U.S. and around the world. No matter your role, you’ll be part of a team helping clients navigate complexity and move forward with clarity.

We are proud to be an ESOP company, offering participants a stake in the firm’s success through beneficial ownership and a unique opportunity to enhance their financial well‑being. As a qualified retirement plan, the ESOP is a meaningful addition to our comprehensive compensation and Total Rewards benefits* offerings. It also reinforces an ownership mindset that strengthens our connection to one another, our clients, and the future we’re building together.

Benefits may be subject to eligibility requirements.

Equal Opportunity Employer, including disability/vets

All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, disability or protected veteran status.

"BDO USA, P.A. is an EO employer M/F/Veteran/Disability"